People v. Morpus
REITERATIONFacts
The Antecedents: On September 16, 1949, Mariano Morpus y Felinggon was charged with illegal possession of a .32 caliber revolver without the necessary permit, in violation of section 878 in connection with section 2692 of the Revised Administrative Code, as amended by Commonwealth Act No. 56 and Republic Act No. 4. Procedural History: The defendant filed a motion to quash, asserting that the information did not state sufficient facts to constitute an offense, relying on the authority of People vs. Santos Lopez y Jacinto. The prosecution opposed the motion. The lower court granted the motion to quash and dismissed the case, citing People vs. Santos Lopez y Jacinto. The Petition: The fiscal appealed the order of dismissal, arguing that the doctrine in People vs. Santos Lopez y Jacinto was not applicable to the case of Mariano Morpus y Felinggon.
Issue(s)
Whether the doctrine in People vs. Santos Lopez y Jacinto applies to a case of illegal possession of firearms occurring on September 15, 1949. Whether the information filed against Mariano Morpus y Felinggon sufficiently states facts constituting a criminal offense.
Ruling
The appealed order is reversed, with costs against the appellee.
Ratio Decidendi
On Issue 1: The Supreme Court held that the doctrine in People vs. Santos Lopez y Jacinto does not apply to the present case due to the difference in the timing of the alleged possession. The Court invoked the maxim 'Distinque temporal et concordabis jura' (Distinguish time and you will harmonize laws) to clarify the relationship between the statutes and the precedent. In the Santos Lopez case, the possession occurred on August 21, 1946, which was within the period where criminal liability was temporarily lifted by Section 2 of Republic Act No. 4 and the Presidential Proclamation. However, the Court clarified that this specific suspension of criminal liability terminated on August 31, 1946. Because the illegal acts in Santos Lopez happened before the expiration of the suspension, the accused therein could not be punished. In contrast, the current accused was found in possession in 1949, well after the amnesty period had ended. On Issue 2: The Court ruled that the information against Morpus sufficiently stated a cause of action because the general law prohibiting unauthorized possession was in full effect at the time of the offense. Once the temporary suspension of Republic Act No. 4 terminated on August 31, 1946, the general rule of the Revised Administrative Code making it unlawful to possess firearms without a permit again prevailed. Since the information alleged that Morpus possessed a firearm without a permit on September 15, 1949, he had transgressed the law. The defendant must now proceed to trial where he may prove any valid defense or exculpation he might have. The dismissal by the lower court was therefore premature and based on a misapplication of temporal law.
Main Doctrine
The temporary lifting of criminal liability for mere possession of firearms and ammunition by Republic Act No. 4, which expired on August 31, 1946, did not extend to offenses committed after that date. Possession of firearms after the suspension period terminated is punishable under the general law.